DISH INFRA SERVICES PVT LTD,NOIDA vs. PCIT-1, DELHI

ITA 2448/DEL/2025Status: DisposedITAT Delhi16 September 2026AY 2020-216 pages
AI SummaryAllowed

What were the facts?

The assessee, engaged in infrastructure services, filed a return declaring a loss. The Assessing Officer passed an assessment order with a minor addition. The Principal Commissioner of Income Tax (PCIT) invoked revisionary powers under Section 263, alleging the Assessing Officer failed to conduct proper inquiries regarding depreciation on goodwill.

What did the Tribunal hold?

The Tribunal held that the Assessing Officer had indeed conducted extensive inquiries into the assessee's claims, including depreciation on goodwill, and the assessee had provided satisfactory replies. The Tribunal also noted the consistent allowance of such depreciation in prior and subsequent years.

What were the issues?

The primary issue was whether the PCIT correctly exercised revisionary powers under Section 263, based on the alleged lack of inquiry by the Assessing Officer regarding depreciation on goodwill.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 40(a)(ia),Section 32(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES, ‘A’ NEW DELHI

Before: SHRI ANUBHAV SHARMA

Pronounced: 16.09.2026

PER AMITABH SHUKLA, AM This appeal filed by the assessee is directed against the order of Ld. Principal Commissioner of Income Tax -1, Delhi, dated 31.03.2025 arising out of assessment order dated 28.09.2022 passed under section u/s 143(3) r.w.s. 144B of the Act for the Assessment Year 2020-21. The word ‘Act’ herein this order would mean Income Tax Act, 1961. ITA 2448/DEL/2025

2.

The only issue arising

The order continues below.

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